Reward review · Directive (EU) 2023/970, Articles 4 to 6

From family bands to equal-value pay ranges

Scope
IT · Milan, PL · Kraków, DE · Munich and ES · Barcelona; 3,443 employees on the payroll at 30 June 2026, 36 roles in six families
Market
Eurostat Structure of Earnings Survey 2022 by occupation, aged to mid-2026 with the labour cost index, plus a 8.1% large-employer premium
Data
employees and current bands synthetic, from hr-people-analytics; job evaluation from pay-transparency-readiness-kit; market figures real, with their sources in docs/verification.md
The Pay Transparency Directive asks for pay structures that compare work of equal value on objective, gender-neutral criteria (Article 4), a pay range for every vacancy (Article 5) and accessible criteria for pay and progression (Article 6). This review tests the company's bands against all three. Not legal advice.

The answer

01How the current bands are built

Each band midpoint is a country factor times a family premium times a level step. At every level the premium is the same:

FamilyItaly L3 midpointvs Customer ServiceShare of staffWomen
Customer Service€37k+0%29%55%
Operations€40k+6%25%48%
Tech€52k+39%16%41%
Sales€44k+17%13%51%
Finance€46k+22%10%47%
HR€42k+11%8%58%

The job evaluation scores the four Article 4(4) criteria (skills, effort, responsibility, working conditions) and groups roles into seven grades of equal value. Customer Service and Operations score high on effort and working conditions, which the family premiums ignore.

Italy: one range per grade where there were up to six family bandsNew range by grade (full-time annual base pay) and the current midpoint of each role in the grade€0k€20k€40k€60k€80k€100k€120k€140kGrade AGrade A: €26k to €33k, midpoint €29kHR L1: current midpoint €26kSales L1: current midpoint €27kFinance L1: current midpoint €29kTech L1: current midpoint €32kGrade BGrade B: €28k to €36k, midpoint €32kCustomer Service L1: current midpoint €23kOperations L1: current midpoint €25kHR L2: current midpoint €32kFinance L2: current midpoint €36kTech L2: current midpoint €41kGrade CGrade C: €30k to €39k, midpoint €34kCustomer Service L2: current midpoint €29kOperations L2: current midpoint €31kSales L2: current midpoint €34kGrade DGrade D: €37k to €52k, midpoint €45kCustomer Service L3: current midpoint €37kOperations L3: current midpoint €40kHR L3: current midpoint €42kSales L3: current midpoint €44kFinance L3: current midpoint €46kTech L3: current midpoint €52kGrade EGrade E: €49k to €68k, midpoint €58kCustomer Service L4: current midpoint €49kOperations L4: current midpoint €52kHR L4: current midpoint €55kSales L4: current midpoint €57kFinance L4: current midpoint €60kTech L4: current midpoint €68kGrade FGrade F: €65k to €97k, midpoint €81kCustomer Service L5: current midpoint €68kOperations L5: current midpoint €72kHR L5: current midpoint €75kSales L5: current midpoint €79kFinance L5: current midpoint €83kTech L5: current midpoint €94kGrade GGrade G: €86k to €138k, midpoint €112kCustomer Service L6: current midpoint €94kOperations L6: current midpoint €99kHR L6: current midpoint €104kSales L6: current midpoint €109kFinance L6: current midpoint €114kTech L6: current midpoint €130knew range, with its midpointcurrent band midpoint of a role in the grade
Italy: current midpoints and new ranges

02The market, country by country

Each role is matched to an ISCO major group (a contact centre agent to clerical support workers, a Tech L3 to professionals) and priced on Eurostat's mean base pay for that group: earnings minus annual bonuses, aged from 2022 with the labour cost index for wages and salaries, and raised by 8.1%, what enterprises of 1,000+ pay over enterprises of 10+ in Germany, Spain and Poland (Italy's figure is confidential).

One pay scale, four markets: Kraków +13.6%, Munich −9.7%Payroll against what large employers pay for the same occupations, grades A–E, mid-2026−20%−10%market+10%+20%IT · MilanIT · Milan: payroll −7.0% against market−7.0%PL · KrakówPL · Kraków: payroll +13.6% against market+13.6%DE · MunichDE · Munich: payroll −9.7% against market−9.7%ES · BarcelonaES · Barcelona: payroll −1.0% against market−1.0%
Payroll against market
EntityPayroll against marketCurrent bands vs ItalyMarket vs ItalyLabour cost growth, 2025
IT · Milan−7.0%100%100%3.0%
PL · Kraków+13.6%81%66%8.9%
DE · Munich−9.7%146%151%3.9%
ES · Barcelona−1.0%96%90%3.0%

Grades A–E only: ISCO group 1 averages every manager, from a shop manager to an Italian dirigente, so it is not a fair yardstick for grades F and G.

03The new structure

One range per grade and country. The midpoint is the country's market level times a grade index: the progression between grades in today's bands, with the family premiums averaged out and each grade at least 8% above the one below. The range runs from 30% wide at grade A to 60% at grade G.

GradeIndexIT · MilanPL · KrakówDE · MunichES · Barcelona
A0.6625,592 – 33,27072,081 – 93,70638,675 – 50,27823,112 – 30,046
B0.7127,640 – 35,93277,848 – 101,20241,770 – 54,30024,961 – 32,449
C0.7729,851 – 38,80684,076 – 109,29845,111 – 58,64426,958 – 35,045
D1.0037,095 – 51,933104,479 – 146,27056,058 – 78,48233,500 – 46,900
E1.3148,686 – 68,160137,124 – 191,97473,574 – 103,00443,967 – 61,554
F1.8164,545 – 96,817181,792 – 272,68897,541 – 146,31158,289 – 87,434
G2.5186,058 – 137,692242,383 – 387,813130,052 – 208,08277,717 – 124,348

Full-time annual base pay: euro, Poland in zloty. The grade index is 1 at grade D.

04Who moves

41% of Poland above the new maximum, 40% of Germany below the minimumEmployees on the payroll at 30 June 2026 against the range of their gradeBelow the minimumWithinAbove the maximumIT · MilanIT · Milan: 34% below the minimum34%IT · Milan: 54% within the rangeIT · Milan: 12% above the maximum12%PL · KrakówPL · Kraków: 6% below the minimum6%PL · Kraków: 53% within the rangePL · Kraków: 41% above the maximum41%DE · MunichDE · Munich: 40% below the minimum40%DE · Munich: 52% within the rangeDE · Munich: 8% above the maximum8%ES · BarcelonaES · Barcelona: 20% below the minimum20%ES · Barcelona: 63% within the rangeES · Barcelona: 16% above the maximum16%
Positions against the new ranges
EntityBelow minimumAbove maximumCost to minimumof which womenPay above maximumYears to absorb
IT · Milan357123€1.14M63%€0.52M3.0
PL · Kraków75473€0.10M54%€2.28M1.3
DE · Munich29362€1.57M54%€0.29M1.3
ES · Barcelona9981€0.22M63%€0.38M3.2

Costs are annual full-time-equivalent base pay, before employer contributions. Years to absorb: the median time for the maximum to reach a frozen salary at the country's 2025 labour cost growth.

Without family premiums, Tech sits 14%–43% above the midpointAverage compa-ratio against the new equal-value midpoint, by family: dot = mean of the four countries, line = their range0.70.91.01.11.31.5new midpointCustomer ServiceCustomer Service: 0.86 on average, 0.78 to 1.00 across countries0.86OperationsOperations: 0.91 on average, 0.83 to 1.04 across countries0.91TechTech: 1.25 on average, 1.14 to 1.43 across countries1.25SalesSales: 1.02 on average, 0.93 to 1.18 across countries1.02FinanceFinance: 1.10 on average, 1.01 to 1.25 across countries1.10HRHR: 0.99 on average, 0.91 to 1.13 across countries0.99
Compa-ratio by family

Poland's position is a policy choice the company never made explicitly. Setting its midpoints above the local market changes the picture:

Poland positioned atBelow minimumAbove maximumPay above maximumCost to minimum
100%6%41%€2.28M€0.10M
110%14%22%€1.13M€0.33M
120%29%12%€0.50M€0.83M

The wider the positioning, the more staff fall below the minimum instead: Polish pay is dispersed more widely than a single range can hold.

05Job advertisements and progression

Article 5 gives applicants the right to the starting pay or its range before the interview, based on objective, gender-neutral criteria, and bars employers from asking about pay history. The range for each role follows from its grade:

RoleGradeIT · MilanPL · KrakówDE · MunichES · Barcelona
Customer Service L1BEUR 27,500 – 36,000 per yearPLN 6,400 – 8,500 per monthEUR 41,500 – 54,500 per yearEUR 24,500 – 32,500 per year
Operations L2CEUR 29,500 – 39,000 per yearPLN 7,000 – 9,200 per monthEUR 45,000 – 59,000 per yearEUR 26,500 – 35,500 per year
Tech L3DEUR 37,000 – 52,000 per yearPLN 8,700 – 12,200 per monthEUR 56,000 – 78,500 per yearEUR 33,000 – 47,000 per year
Finance L4EEUR 48,500 – 68,500 per yearPLN 11,400 – 16,000 per monthEUR 73,500 – 103,500 per yearEUR 43,500 – 62,000 per year
Sales L5FEUR 64,500 – 97,000 per yearPLN 15,100 – 22,800 per monthEUR 97,500 – 146,500 per yearEUR 58,000 – 87,500 per year

Rounded outwards to €500 or PLN 1,000 a year (PLN 100 a month), so the published range always contains the real one. Poland advertises monthly gross pay, as its job market does; the others annual. Article 6 then asks for the criteria that move someone through the range: the proposal is time in grade and performance against the role's objectives, with position in range reviewed each year.

06Recommendations

  1. Adopt one structure by grade. Keep a family premium only where the company can document an objective, gender-neutral market reason, review it every year, and have counsel test it against national law.
  2. Close the gaps to the minimum over two pay reviews, starting with the grades where women are furthest below: €3.02M a year in total.
  3. Protect pay above the maximum, don't cut it. Hold increases to lump sums until the range catches up, and say so in writing to the people affected.
  4. Decide Poland's positioning deliberately. Paying above the local market can be a sound retention choice in Kraków; it should be a decision with a number, not the side-effect of a single scale.
  5. Publish ranges in every vacancy in the countries that have transposed Article 5, and remove pay-history questions from applications and interviews.
  6. Price the jobs on a salary survey before implementing. Eurostat gives reliable country levels by occupation, not level-by-level market rates.

07Method and limits